Compliance Statement

Relevant National Competent Authority: AFM Compliance Statement Euronext Indices Euronext Amsterdam

Version notes latest version February 2020 Version Version notes Euronext Amsterdam 1 April 2019 Initial version. February 2020 Updated version including all new indices since 2 initial version. 3 4 5 6

Note: addition of indices does not lead to a new version of this statement. The lists will be kept up to date.The most recent update of the list was issued 02-Feb-2021. Only changes in significant indices and cessations of indices are marked as new version of the Compliance statement.

This publication is for information purposes only and is not a recommendation to engage in investment activities. This publication is provided “as is” without representation or warranty of any kind. Whilst all reasonable care has been taken to ensure the accuracy of the content, Euronext does not guarantee its accuracy or completeness. Euronext will not be held liable for any loss or damages of any nature ensuing from using, trusting or acting on information provided. All proprietary rights and interest in or connected with this publication shall vest in Euronext. No part of it may be redistributed or reproduced in any form without the prior written permission of Euronext.

Euronext refers to Euronext N.V. and its affiliates. Information regarding trademarks and intellectual property rights of Euronext is located at

For further information in relation to Euronext Indices please contact: [email protected]

1 INTRODUCTION……………………………...…………………….……… 3

2 SIGNIFICANT INDICES………..…………………...…………….…….. 5

3 NON-SIGNIFICANT INDICES…….…………………………………… 7

4 List of Significant and Non-Significant Benchmarks.…… 11

1. INTRODUCTION Compliance statement under Article 25 (7) of Regulation (EU) 2016/1011

Euronext NV operates via its wholly owned subsidiaries Euronext Amsterdam N.V(Euronext Amsterdam), Euronext Brussels S.A/N.V (Euronext Brussels), Euronext Lisbon – SGMR, SA (Euronext Lisbon), Euronext Paris S.A (Euronext Paris) and The Irish Stock Exchange plc (Euronext Dublin) (collectively the “Benchmark Administrators” and individually the "Administrator") a leading benchmark and strategy index franchise that measures different segments of the Euronext and other global markets, including AEX®, BEL 20®, CAC 40®, ISEQ® and PSI 20®. Euronext has a long standing major interest in the management of benchmarks and indexes.

Overview of Documents relating to Euronext Indices

The following documents should be read in conjunction with this document or provide other relevant information for the reader: • Benchmark Statement • Compliance Statement • Governance Euronext Indices • Rulebook of each Family Of Indices • Procedures Euronext Indices • Rules Of Procedure Independent Supervisors • Benchmark Oversight Committee Charter • List of Indices All of these documents are available on or via the following link:

https://live.euronext.com/products-indices/index-rules

BENCHMARK STATEMENT The Benchmark Statement identifies the primary features of an index family or families of indices in the context of the EU Benchmark regulation.

COMPLIANCE STATEMENT The Compliance Statement provides details, for both significant and non-significant benchmarks, which provisions the administrator has chosen not to apply, and offers an explanation as to why it is appropriate not to apply each provision.

RULEBOOK OF EACH FAMILY OF INDICES Each index is part of an index family that shares the basis for selection (universe) and which is managed in a comparable way. A separate rulebook is provided for each index family that will describe the specific features of that index family as well as specific elements of each index within that family. The rulebooks include also the methodology section which includes all aspects that apply for the • periodical reviews, • the calculation, and • treatment of corporate actions.

PROCEDURES The procedures describe the various policies that are applied in various situations for all Euronext Indices:

• Correction Policy • Announcement Policy • Complaints Procedure • Consultations Procedure • Procedure for Cessation of Indices

RULES OF PROCEDURE INDEPENDENT SUPERVISORS For each Independent Supervisor Euronext publishes a ‘Rule of Procedure’ that describes the responsibilities and composition of each Independent Supervisor.

BENCHMARK OVERSIGHT COMMITTEE CHARTER The Benchmark Oversight Committee Charter describes the role and responsibilities of the Benchmark Oversight Committee.

LIST OF INDICES PER BENCHMARK FAMILY An overview of all indices provided by Euronext Indices with identification of their respective administrator and regulator. The list provides all reference information, identifies the status of each benchmark and contains links to the relevant index family rulebooks.

(c) 2020 Euronext N.V. 4 of 15 version February 2020 Compliance Statement Euronext Indices Euronext Amsterdam 2. Significant Benchmarks The following section includes: • The significant benchmark in respect of which provisions do not apply, • The provision that the administrator has chosen not to apply, and • An explanation as to why it is appropriate not to apply each provision.

Each section should be completed for any identified group of significant benchmarks provided by the administrator in respect of which: • The same provisions are not complied with, and • The same explanations for non-compliance apply. Euronext Amsterdam chooses not to apply the following provisions of Regulation (EU) 2016/1011 with respect to its significant benchmarks listed in Chapter 4.

The benchmark statement(s) and relevant Rule books are published here: https://live.euronext.com/products-indices/index-rules Article 4 (2): The provision of a benchmark shall be operationally separated from any part of an administrator's business that may create an actual or potential conflict of interest.

Positioning of Euronext benchmark business in the Euronext group 1. Euronext management might be involved in index management as well as in other departments, such as the Listing department. 2. The Independent Supervisor is chaired by a Euronext representative i.e. the country relevant CEO.

Rationale for exemption foreseen in BMR provision 25 With respect of the potential conflicts of interest that might arise, mitigation means are implemented. 1. The Benchmark Oversight Committee (BOC) implemented an approach whereby any problematic matters identified are addressed urgently outside the periodic review cycle of indices 2. The existing decision process to admit or exclude components of the main indices is carried out by the Independent Supervisor which voting members are not employed by Euronext or its affiliates.

3. Managing Board members are excluded from the voting process of the Independent Supervisor. 4. The publicly available Rules of procedure for the Independent Supervisor Committee include the following section: a. Members of the Independent Supervisor shall avoid any conflicts of interest between the work related to Euronext’s indices and their own direct or indirect personal or material interests. Each member shall immediately report any potential or actual conflict of interest to Euronext.

(c) 2020 Euronext N.V. 5 of 15 version February 2020 Compliance Statement Euronext Indices Euronext Amsterdam b. In cases where Euronext establishes that a potential or actual conflict of interest exists, it may take appropriate action against the relevant Independent Supervisor member(s), including but not limited to restriction of voting rights, suspension or dismissal. c. Independent Supervisor Committee’s minutes shall record reported conflicts of interest and related actions or measures.

5. The recruiting process of new external members of the Independent Supervisor includes a training session with Compliance and upfront reporting of potential conflicts.

6. Rules for attendees to the Independent Supervisor meetings: Guests/Experts:

7. Guests/Experts invited to the Independent Supervisor Committee have no advocacy role for issuers and shall refrain to suggest directly or indirectly arbitrage between issuers.

8. Embargo period: Guests/Experts shall not discuss with Independent Supervisor’s members during the 5 days prior to the meeting.

9. Embargo period for issuers: Chairmen, guests and experts shall not take any position regarding Index topic nor give any suggestion or supplementary information to issuers on an on-going basis and must refrain to discuss Index topics with issuers during 5 days prior to the meeting.

10. Segregation of operational teams: Operational teams that manage the Benchmark do not report to the Listing head and are bound by the confidentiality principle enforced across the Group “need to know principle”. ‘Need to know principle’ means that topics concerning indices and issuers cases shall be kept by employees and concerned teams and not be discussed with other employees or third parties.

11. Index Operations manages the day-to-day of the index and prepares the decisions of the Independent Supervisor Committee. This team belongs to Market Surveillance division and Index design team belongs to the Global sales division.

The following section includes: • The non-significant benchmark in respect of which provisions do not apply, • The provision that the administrator has chosen not to apply, and • An explanation as to why it is appropriate not to apply each provision.

Each section should be completed for any identified group of non-significant benchmarks provided by the administrator in respect of which: • The same provisions are not complied with, and • The same explanations for non-compliance apply. Euronext Amsterdam chooses not to apply the following provisions of Regulation (EU) 2016/1011 with respect to its non-significant benchmarks listed in Chapter 4.

The benchmark statement(s) and relevant Rule books are published here: https://live.euronext.com/products-indices/index-rules

Article 4 (2): The provision of a benchmark shall be operationally separated from any part of an administrator's business that may create an actual or potential conflict of interest.

Rationale for exemption foreseen in BMR provision 25 With respect of the potential conflicts of interest that might arise, mitigation means are implemented.

1. The Benchmark Oversight Committee (BOC) implemented an approach whereby any problematic matters identified are addressed urgently outside the periodic review cycle of indices

2. The existing decision process to admit or exclude components of the main indices is carried out by the Independent Supervisor which voting members are not employed by Euronext or its affiliates.

3. Managing Board members are excluded from the voting process of the Independent Supervisor.

(c) 2020 Euronext N.V. 7 of 15 version February 2020 Compliance Statement Euronext Indices Euronext Amsterdam 4. The publicly available Rules of procedure for the Independent Supervisor Committee include the following section: a. Members of the Independent Supervisor shall avoid any conflicts of interest between the work related to Euronext’s indices and their own direct or indirect personal or material interests. Each member shall immediately report any potential or actual conflict of interest to Euronext. b. In cases where Euronext establishes that a potential or actual conflict of interest exists, it may take appropriate action against the relevant Independent Supervisor member(s), including but not limited to restriction of voting rights, suspension or dismissal. c. Independent Supervisor Committee’s minutes shall record reported conflicts of interest and related actions or measures.

5. The recruiting process of new external members of the Independent Supervisor includes a training session with Compliance and upfront reporting of potential conflicts.

6. Rules for attendees to the Independent Supervisor meetings: Guests/Experts:

7. Guests/Experts invited to the Independent Supervisor Committee have no advocacy role for issuers and shall refrain to suggest directly or indirectly arbitrage between issuers.

8. Embargo period: Guests/Experts shall not discuss with Independent Supervisor’s members during the 5 days prior to the meeting.

Article 4 (8): “An administrator shall establish specific internal control procedures to ensure the integrity and reliability of the employee or person determining the benchmark, including at least internal sign-off by management before the dissemination of the benchmark.”

Rationale for Article 4 (8): Sign-off before the dissemination by management is part of the responsibilities by the Management Body for all significant benchmarks. The sign-off before dissemination of non-significant benchmarks is performed by the associated Independent Supervisor if one exists. If there is no independent Supervisor, the head of Index Design is responsible for the sign-off before (c) dissemination.2020 Euronext N.V. 8 of 15 version February 2020 Rationale for Article 4 (8): Sign-off before the dissemination by management is part of the responsibilities by the Management ComplianceBody for allStatement significant Euronext benchmarks. Indices The sign-off before dissemination of non-significantEuronext benchmarks Amsterdam is performed by the associated Independent Supervisor if one exists. If there is no independent Supervisor, the head of Index Design is responsible for the sign-off before dissemination.

Article 5 (3) (a) to (b): 5 (3): “The oversight function shall operate with integrity and shall have the following responsibilities, which shall be adjusted by the administrator based on the complexity, use and vulnerability of the benchmark: (a) reviewing the benchmark's definition and methodology at least annually; (b) overseeing any changes to the benchmark methodology and being able to request the administrator to consult on such changes;

Rationale Article 5 (3) (a) to (b): 5 (3) (a) Non-significant Benchmarks with known AUM are reviewed at a minimum each year. In addition, for non-significant benchmarks of which the known AUM is zero (0), the Oversight committee implemented a risk based approach to ensure that any problematic matters are addressed in a timely manner whilst allowing all such benchmarks to be reviewed periodically. This approach is based on the following reasons: the non-significant benchmarks are not vulnerable to manipulation as they are based on publicly available data which do not use any contributed data.

The complexity of the provision of the benchmark is measured as low, as Euronext does not use any contributed data. Euronext uses transaction data for all equity price indices. Number of unique sources of input data is limited to two (OPTIQ and Thomson Reuters). Euronext has sufficient technical means to process the input data continuously and robustly.

5 (3) (b) overseeing any changes in the benchmark methodology: as the Oversight function oversees material changes.

Article 13 (2)(a) and (b) An administrator shall develop, operate and administer the benchmark and methodology transparently. To that end, the administrator shall publish or make available the following information: 2. The procedures required under point (c) of paragraph 1 shall provide for: (a) advance notice, with a clear time frame, that gives the opportunity to analyze and comment upon the impact of such proposed material changes; and (b) the comments referred to in point (a) of this paragraph, and the administrator's response to those comments, to be made accessible after any consultation, except where confidentiality has been requested by the originator of the comments.

Material changes for Non-Significant Benchmarks are announced 2 months in advance. This allows concerned third parties to analyse the proposed changes and if necessary discuss with Euronext the proposed changes. Due to the limited number of products, funds managers and very low or non-existing AUM, Euronext considers that the consultation process described in 13 (2) (2) is not proportionate to the products and AUM related to its non-significant benchmarks.

Article 14 (2) An administrator shall monitor input data and contributors in order to be able to notify the competent authority and provide all relevant information where the administrator suspects that, in relation to a benchmark, any conduct has taken place that may involve manipulation or attempted manipulation of the benchmark, under Regulation (EU) No 596/2014, including collusion to do so.

Rationale for Article 14(2) Although Euronext already reports market manipulation to the regulators (MAR) for our own market activity, we do not monitor market manipulation of non-Euronext exchange traded data of which some non-significant benchmarks are based.

(c) 2020 Euronext N.V. 10 of 15 version February 2020 Compliance Statement Euronext Indices Euronext Amsterdam 4. List of Significant and Non-Significant Benchmarks Significant indices Index name Index Family ISIN Code Mnemo

1 AEX NL0000000107 AEX AEX-Index

2 AEX QS0011131990 AEXGR AEX GR

3 AEX QS0011211156 AEXNR AEX NR

Non-Significant indices Index Family ISIN Code Mnemo Index name

4 AEX NL0010614491 AEXAT AEX All-Tradable

5 AEX NL0010614541 ATAWG AEX All-Tradable Alternative Weight GR

6 AEX NL0010614533 ATAWN AEX All-Tradable Alternative Weight NR

7 AEX NL0010614525 AETAW AEX All-Tradable Alternative Weighting

8 AEX NL0010614517 AEXTG AEX All-Tradable GR

9 AEX NL0010614509 AEXTN AEX All-Tradable NR

# AEX QS0011204763 AMXGR AMX GR

# AEX QS0011211164 AMXNR AMX NR

# AEX NL0000249274 AMX AMX-Index

# AEX QS0011204995 ASCXG AScX GR

# AEX QS0011211172 ASCXN AScX NR

# AEX NL0000249142 ASCX AScX-Index

# AEX All-Share and Sector NL0000249100 AAX AEX All-Share Index

# AEX All-Share and Sector QS0011224977 AAXG AEX All-Share Index GR

# AEX All-Share and sector QS0011016480 NLBM AEX Basic Materials

# AEX All-Share and sector QS0011225396 NLBMG AEX Basic Materials GR

# AEX All-Share and sector QS0011016530 NLCG AEX Consumer Discretionary

# AEX All-Share and sector QS0011225404 NLCGG AEX Consumer Discretionary GR

# AEX All-Share and sector QS0011016563 NLCS AEX Consumer Staples

# AEX All-Share and sector QS0011225420 NLCSG AEX Consumer Staples GR

# AEX All-Share and sector QS0011016472 NLOG AEX Energy

# AEX All-Share and sector QS0011224829 NLOGG AEX Energy GR

# AEX All-Share and sector QS0011016605 NLFIN AEX Financials

# AEX All-Share and sector QS0011224522 NLFNG AEX Financials GR

# AEX All-Share and sector QS0011016555 NLHC AEX Health Care

# AEX All-Share and sector QS0011224589 NLHCG AEX Health Care GR

# AEX All-Share and sector QS0011016506 NLIN AEX Industrials

# AEX All-Share and sector QS0011224662 NLING AEX Industrials GR

# AEX All-Share and sector NL0014787053 NLRE AEX Real Estate

# AEX All-Share and sector NL0014787061 NLREG AEX Real Estate GR

# AEX All-Share and sector NL00150006J3 NLUT AEX UTILITIES

# AEX All-Share and sector NL00150006K1 NLUTG AEX UTILITIES GR

# AEX All-Share and sector QS0011016613 NLTEC AEX Technology

# AEX All-Share and sector QS0011224936 NLTCG AEX Technology GR

# AEX All-Share and sector QS0011016589 NLTEL AEX Telecommunications

# AEX All-Share and sector QS0011224944 NLTLG AEX Telecommunications GR

# AEX-DI QS0011158126 AEXDI AEX Dividend Index

# AEX-EW QS0011159744 AEXEW AEX Equal Weight

# AEX-EW QS0011211222 AEXEG AEX Equal Weight GR

# AEX-EW QS0011211206 AEXEN AEX Equal Weight NR

# AEX-EXT QS0011257225 AEEXT AEX EXT

# AEX-HD QS0011115274 AEXHD AEX High Dividend NR

# Euronext BeNe 40 Index NL0011376116 BNEW Euronext BeNe 40 Equal Weight

# Euronext BeNe 40 Index NL0011376132 BNEWG Euronext BeNe 40 Equal Weight GR

# Euronext BeNe 40 Index NL0011376124 BNEWN Euronext BeNe 40 Equal Weight NR

# Euronext BeNe 40 Index NL0011376140 BNEWE Euronext BeNe 40 EW Excess Return Euronext BeNe 40 Equal Weight Volatility Euronext BeNe 40 Index VT NL0012081418 BNEWV # Target # Euronext BeNeLux Low Risk 20 NL0012294235 EBLRE Euronext BeNeLux Low Risk 20

Euronext BeNeLux Low Risk 20 NL0012294268 EBLRD Euronext BeNeLux Low Risk 20 D 4.5% #

Euronext BeNeLux Low Risk 20 NL0012294250 EBLRG Euronext BeNeLux Low Risk 20 GR #

Euronext BeNeLux Low Risk 20 NL0012294243 EBLRN Euronext BeNeLux Low Risk 20 NR #

Euronext Core Europe EW NL0012254635 EC1EW Euronext Core Europe 100 EW #

(c) 2020 Euronext N.V. 12 of 15 version February 2020 Compliance Statement Euronext Indices Euronext Amsterdam Euronext Core Europe 100 EW Decrement Euronext Core Europe EW NL0012254650 EC1ED # 5% GR Euronext Core Europe 100 EW Decrement Euronext Core Europe EW NL0012375356 COREU # 5% NR

Euronext Core Europe EW NL0012254643 EC1EG Euronext Core Europe 100 EW GR #

Euronext Core Europe EW NL0012375349 COREN Euronext Core Europe 100 EW NR #

Euronext Core Europe EW NL0012483903 COR3P Euronext Core Europe 30 EW # Euronext Core Europe 30 EW Decrement Euronext Core Europe EW NL0012483945 COR3D # 5% GR Euronext Core Europe 30 EW Decrement Euronext Core Europe EW NL0012483929 COR30 # 5% NR

Euronext Core Europe EW NL0012483937 COR3G Euronext Core Europe 30 EW GR #

Euronext Core Europe EW NL0012483911 COR3N Euronext Core Europe 30 EW NR #

# Euronext Eur 500 EZ 300 NL0013273014 EU500 Euronext Europe 500

# Euronext Eur 500 EZ 300 NL0013273030 EU5GR Euronext Europe 500 GR

# Euronext Eur 500 EZ 300 NL0013273022 EU5NR Euronext Europe 500 NR

# Euronext Eur 500 EZ 300 NL0013273048 EZ300 Euronext Eurozone 300

# Euronext Eur 500 EZ 300 NL0013273063 EZ3GR Euronext Eurozone 300 GR

# Euronext Eur 500 EZ 300 NL0013273055 EZ3NR Euronext Eurozone 300 NR

# Euronext Eurozone 150 EW NL0012949101 EZ15P Euronext Eurozone 150 EW Euronext Eurozone 150 EW Decrement Euronext Eurozone 150 EW NL0012949135 EZ150 # 5% # Euronext Eurozone 150 EW NL0012949127 EZ15G Euronext Eurozone 150 EW GR

# Euronext Eurozone 150 EW NL0012949119 EZ15N Euronext Eurozone 150 EW NR

# Euronext Eurozone 40 EW NL0012731871 EZ40P Euronext Eurozone 40 EW

# Euronext Eurozone 40 EW NL0012731905 EZ40 Euronext Eurozone 40 EW Decrement 5%

# Euronext Eurozone 40 EW NL0012731897 EZ40G Euronext Eurozone 40 EW GR

Euronext Eurozone 40 EW NL0012731889 EZ40N Euronext Eurozone 40 EW NR #

# Euronext Eurozone 60 EW NL0012846265 EZ60P Euronext Eurozone 60 EW Euronext Eurozone 60 EW Decrement 50 Euronext Eurozone 60 EW NL0012846299 EZ60 # Points # Euronext Eurozone 60 EW NL0012846281 EZ60G Euronext Eurozone 60 EW GR

# Euronext Eurozone 60 EW NL0012846273 EZ60N Euronext Eurozone 60 EW NR

# Euronext Eurozone 70 EW NL0012846174 EZ70P Euronext Eurozone 70 EW

# Euronext Eurozone 70 EW NL0012846208 EZ70 Euronext Eurozone 70 EW Decrement 5%

# Euronext Eurozone 70 EW NL0012846190 EZ70G Euronext Eurozone 70 EW GR

# Euronext Eurozone 70 EW NL0012846182 EZ70N Euronext Eurozone 70 EW NR

# Euronext Eurozone 80 EW NL0013025653 EZ80P Euronext Eurozone 80 EW

# Euronext Eurozone 80 EW NL0013025687 EZ80D Euronext Eurozone 80 EW Decrement 5%

# Euronext Eurozone 80 EW NL0013025679 EZ80G Euronext Eurozone 80 EW GR

# Euronext Eurozone 80 EW NL0013025661 EZ80N Euronext Eurozone 80 EW NR Euronext Eurozone Mid and NL0013025810 EZMLP EN Eurozone Mid and Large 60 EW # Large 60 EW Euronext Eurozone Mid and NL0013025844 EZML6 EN Eurozone Mid and Large 60 EW D 50P # Large 60 EW Euronext Eurozone Mid and NL0013025836 EZMLG EN Eurozone Mid and Large 60 EW GR # Large 60 EW Euronext Eurozone Mid and NL0013025828 EZMLN EN Eurozone Mid and Large 60 EW NR # Large 60 EW Euronext Eurozone Next 100 NL0012949143 EZN1P EN Eurozone Next 100 EW # EW Euronext Eurozone Next 100 NL0012949176 EZNE1 EN Eurozone Next 100 EW Decrement 5% # EW Euronext Eurozone Next 100 NL0012949168 EZN1G EN Eurozone Next 100 EW GR # EW Euronext Eurozone Next 100 NL0012949150 EZN1N EN Eurozone Next 100 EW NR # EW Euronext Founding Members Euronext Founding Members Europe 50 NL0012730451 EFMEP # Europe 50 EW EW Euronext Founding Members Euronext Founding Members Europe 50 NL0012730485 EFMED # Europe 50 EW EW Decrement 5 Euronext Founding Members Euronext Founding Members Europe 50 NL0012730477 EFMEG # Europe 50 EW EW GR Euronext Founding Members Euronext Founding Members Europe 50 NL0012730469 EFMEN # Europe 50 EW EW NR

Euronext North America 500 NL0015436114 NA500 Euronext North America 500 #

Euronext North America 500 NL0015436122 NA5NR Euronext North America 500 NR #

Euronext North America 500 NL0015436130 NA5GR Euronext North America 500 GR # Euronext Transatlantic Leaders NL0013216468 EUS5P EN Transatlantic Leaders 50 EW # 50 EW Euronext Transatlantic Leaders NL0013216492 EUS5D EN Transatlantic Leaders 50 EW D5% # 50 EW Euronext Transatlantic Leaders NL0013216484 EUS5G EN Transatlantic Leaders 50 EW GR # 50 EW

(c) 2020 Euronext N.V. 14 of 15 version February 2020 Compliance Statement Euronext Indices Euronext Amsterdam Euronext Transatlantic Leaders NL0013216476 EUS5N EN Transatlantic Leaders 50 EW NR # 50 EW